EMPLOYER INTERFERENCE; RESTRAINT, COERCION; SURVEILLANCE – Statements to Employees, Creating Impression of Surveillance

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An employer engages in unlawful surveillance when the employer photographs or videotapes employees or openly engages in recordkeeping of employees participating in union activities. (Lake Tahoe Unified School District (1999) PERB Decision No. 1361, adopting warning letter at p. 2.) “Photographing and recordkeeping are proscribed because of their ‘tendency to intimidate.’” (County of San Bernardino (2018) PERB Decision No. 2556-M, p. 20.) Here, the Board found that the employer engaged in unlawful surveillance when it, created the impression that it was transmitting, and possibly recording, audio during a meeting of union representatives and bargaining unit members in the medical center’s cafeteria. (pp. 42-48.)